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HMRC have taken on board many of the points made to them about the original proposals. However, some uncertainties remain. In particular, HMRC have introduced a new change to the statutory requirements for CSOPs and SAYE schemes relating to the exercise of an option by the estate of a deceased option holder, which needs to be clarified.

The new regime takes effect from 6 April 2014 and our guidance that companies do not need to amend existing HMRC-approved plans before 6 April (unless new grants are to be made imminently) remains.

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